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. … In addition to the diploma program, the school offers 3 courses: “Enhancing Your Webpage with Java”, which is also a credit course in the diploma program [exempt] “Programming in C++”, which is offered as an upgrade program and for which students are graded on a mid term assignment and final exam [exempt] “Supporting and Implementing Windows”, which is not offered as part of the diploma program and for which students are evaluated based on class attendance and participation Certificates are issued to students upon completion of each of the courses. … … [T]he supply of instruction in “Supporting and Implementing Windows” is not exempt under section 8 of Part III of Schedule V, regardless of the fact that a certificate is issued upon successful completion of the course. ... The CRA does not consider an individual to be under instruction and direct supervision while amassing build-up flight time hours. … 55. Where a student purchases hours of dual or solo flight time over and above the minimum time requirements in the federal legislation, the supply of the additional hours is not exempt under section 8 …. 56. ...

. … You may also have to report relevant information on Schedule 130 of your partnership information return if you have IFE or IFR, and have a corporation or a trust as a member. If your partnership has a corporation or a trust as a member, under the rules you should complete the following steps: Provide each member with detailed calculations of the partnership’s IFE and IFR Provide each member with detailed calculations of the RAIFE and RAIFR of any CFA of the partnership Notify each member in writing of their allocated share for the year of: IFE in Canadian exploration expenses, Canadian development expenses, Canadian oil and gas expenses, and foreign resource expenses The income or loss that can reasonably be considered to come from activities funded by a borrowing or other financing that results in exempt interest and financing expenses Filing approach before Schedule 130 is ready Schedule 130 … Schedule 130 information is still required even though the form is not available. … Corporations and trusts … When you report your foreign accrual property income, you must adjust for RAIFE denied under subclause 95(2)(f.11)(ii)(D)(I) and include amounts in respect of a CFA’s partnership under subclause 95(2)(f.11)(ii)(D)(II). ... The calculations should include enough details so that a total amount for each paragraph of the relevant definition is shown (refer to subsection 18.2(1)) A calculation of the proportion in subsection 18.2(2) showing an amount for each variable of the formula A calculation of restricted interest and financing expenses for the year, broken down to show amounts restricted under: Paragraph 12(1)(l.2) Subsection 18.2(2), and Subclauses 95(2)(f.11)(ii)(D)(I) and 95(2)(f.11)(ii)(D)(II) If your corporation or trust is a member of a partnership, you must include the share of all relevant partnership amounts when you calculate the corporation or trust’s ATI, IFE, and IFR. … Partnerships When you submit your partnership information return for the fiscal year, you must include the details of how the partnership calculated its IFE and IFR (refer to subsection 18.2(1)). ...

. … If you do not receive a personalized return, you can use Form GST62 …. ... If the result is a positive amount, include this amount with any other of your adjustments that you make on line 104 – “Adjustments increasing net tax” of the paper GST34-2 return (or include the amount in your line 105 calculation if you are filing electronically). If the result is a negative amount, you can include this amount along with any other adjustment amounts that you make on line 107 – “Adjustments decreasing net tax” of the paper GST34-2 return (or include the amount in your line 108 calculation if you are filing electronically). ...

. … The value of these taxable benefits will be included in the income of the shareholder or employee, unless the family member or friend is also a shareholder or employee, in which case [it] will be included in [their] income …. Re Scenario 2 (sharing of charter price and exceptions) If there is more than one shareholder and/or employee on the flight, then the charter price will be split amongst those shareholders and/or employees. … In the case where: an employee takes a flight for personal purposes on an aircraft that is owned or leased by the employer the taxable benefit was conferred on account of employment and an open market charter is not a viable option based on the unique circumstances of the flight, for example there are demonstrable bona fide security concerns for the employee the taxable benefit will be computed pursuant to scenario 1 for that particular flight. Re Scenario 3 (computation of operating and available-for-use benefit) Operating costs would include all variable and fixed costs incurred/accrued in operating the aircraft during the year. … The available-for-use amount is equal to the original cost of the aircraft multiplied by an imputed monthly interest rate. … [T]he prescribed interest rates contained in [Reg.] 4301(a) … may be used to approximate an imputed equity rate of return for the calculation. ...

. … The relevance of the timing of when a supply is made under section 133 to the application of section 144 is reflected in the wording of the definition of "specified supply" of goods under subsection 178.8(1) … [which] distinguishes between a supply of goods that are imported after the supply is made, and a supply of goods that have been imported in circumstances in which section 144 deems the supply to have been made outside Canada. … [S]hipments of fuel oil to CanCo commenced only after the agreement for the supply was reached …. ...

. …. The TCC determined that Zomaron delivered to the acquirer/processor fully negotiated merchants requiring card payment processing services. … The TCC determined the predominant element in respect of this single supply to be “arranging for” the card payment processing services offered by the acquirer/processor to the merchants and that this “arranging for” activity was a financial service. … Although a supplier may be registered as an ISO/MSP within the Visa/Mastercard networks, the supplier may not always perform the very same services and have the very same obligations and autonomy as another ISO/MSP. … The CRA will only apply the Zomaron decision to supplies made by an ISO/MSP if the same fact situation exists. ...

11 April 2016 CRA Press Release “Government of Canada cracks down on tax evasion”-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) expansion of audit review of aggressive tax avoidance and evasion/embedded lawyers [T]he Government of Canada will invest over $444 million to enhance the Canada Revenue Agency’s (CRA) ability to detect, audit, and prosecute tax evasion – both at home and abroad. …This will result in a twelve-fold increase in the number of tax schemes examined by the CRA…[and] will increase the number of examinations focused on high-risk taxpayers – from 600 per year to 3000 per year – and will bring in $432 million in new tax revenue. ...

. … Authority of agent to bind principal When a person is acting as agent in making a transaction on behalf of a principal, the principal will generally authorize the agent to do something on the principal's behalf. … When a person is acting as agent in making a transaction on behalf of a principal, the agent will have the ability to affect the principal's legal position. The most common example of this is where the agent is authorized to enter into contracts with third parties on the principal's behalf. … [G]iving authority to a person to bind another person in a contract could indicate that a person is acting as agent in making a transaction on behalf of a principal. ...

. … Copper IUDs have a plastic frame that is wound around with copper wire or has copper sleeves. … [H]ormonal IUDs available in Canada contain the drug levonorgestrel which is on the list established under subsection 29.1(1) of the Food and Drugs Act and require a prescription from a physician to be purchased. … Therefore, the supply of hormonal IUDs is zero-rated pursuant to paragraph 2(b) of Part I of Schedule VI…. ...

. … No GST/HST collectible by CMHC on forgivable loans There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … ...